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McAdams On: Lies, @#%&! Lies, and Statistics

NUMBER$: From the very beginning of the fed’s efforts to redistribute
spectrum, the case has been made with kind of math that only wizards and jinn
are privy to.

Our friend the chairman of the Federal Communications Commission is one of the
two, or maybe both. He provided an example of his wizardry at the Wharton
School in Philadelphia this week he said the FCC was “on track to exceed” its
target of freeing up 300 MHz for wireless broadband by 2015.

That benchmark was set in the National Broadband Plan two years ago, when
nearly 70 percent of the 547 MHz already dedicated to wireless broadband was not being used, according to a
commission white paper. But the 2015 benchmark did not take into account that
377 MHz of unused wireless spectrum because it did not support the commission’s arbitrary decision to
reclaim TV Chs. 31-51 (572-698 MHz) – 40 percent of the remaining frequencies
dedicated to broadcast TV. And at no point did the commission provide any
information regarding the build-out status of that 377 MHz, much of it held by
Verizon, AT&T, Dish, Comcast and other conglomerates.

The one guy at the commission who did press
Verizon on its build-out status was shown the door two weeks later. That wasn’t the official line, of course. There
was no official line. Rick Kaplan heads the FCC Wireless Bureau. He writes a
letter asking Verizon what it’s done with the spectrum it won in the last TV
frequency sale – the 2008 700 MHz auction. Rick Kaplan doesn’t head the
Wireless Bureau.

Kaplan was pressing Verizon because Verizon was pressing the commission to OK
it nuptials with Comcast, Time Warner Cable, et al, with their dowry of 122 Advanced
Wireless Spectrum licenses in the 2 GHz band. With that AWS spectrum, Verizon would
no longer need no stinkin’ 700 MHz TV spectrum because it’s lousy for cellphones
without antennas the size of sombreros.

So Verizon says, hey, we’ll get rid of this 700 MHz spectrum to get regulatory
approval to marry the cable companies. And so Mr. Kaplan says that those 700
MHz licenses include specific build-out requirements, and “what
steps to date, if any, has Verizon Wireless taken to deploy mobile services
using the Lower 700 MHz A or B block licenses—either or both? ...On what
timetable has Verizon Wireless been planning to deploy mobile services in these
Lower 700 MHz spectrum blocks?”

Kaplan sent the inquiry to Verizon in a letter dated May 15. On May 30, the FCC
announced that Ruth Milkman was taking his job. This would seem at least to
adhere to the chairman’s stated dedication to operate transparently.

Mr. Kaplan this week was hired by the National Association of Broadcasters to
head up their spectrum policy strategy, to which there’s only one thing to say:
Booyah, dude!

Getting back to numerical magic, our friend the chairman said the commission
would pull off its “audacious” goal of securing 300 MHz by 2015 through a
variety of means. A swath of 75 MHz already designated for AWS is up for
auction plus another 70 MHz now designated for mobile satellite and wireless
communications use, and maybe 35 MHz out of the Big LEO band (1,675
- 1,710 MHz). So that’s 180
of the 300. Fair enough. The rest, however, is to be found in the TV band.

Now we know the National Broadband Plan called for the wholesale clearing of Chs.
31-51 (572-698 MHz), which would have handily provided the remaining 120 MHz. But
there won’t be a wholesale clearing of that band because Congress made
broadcaster participation voluntary, and better yet, prohibited forced
relocation from a UHF to a VHF channel. Dang.

Indeed, the good chairman acknowledged to the Wharton audience that, “While we
can’t know yet exactly how many megahertz incentive auctions will free up, the
opportunity is large, particularly given the highly desirable nature of this
600 MHz spectrum for mobile broadband.”

So here we have the unknown defined as “large,” compared to the FCC’s incentive
auction Notice of Proposed Rulemaking, which repeatedly emphasizes that “we
will not know in advance the amount of spectrum we can make available,” because
no one knows how many broadcasters will participate. And despite Verizon trying
to disabuse itself of TV spectrum, we have even lower frequencies defined as
“highly desirable” for mobile broadband.

Neither of these applies to actual numbers, however, and the number in question
is 120 MHz. So the chairman throws in white spaces – “at least several 6 MHz
channels in most of major markets and more than 100 MHz in many parts of the
country.”

OK. So if white-space spectrum now set aside for unlicensed devices is to be
factored into the 300 MHz-for-broadband target, should it not also be factored
into how much spectrum broadcasters have already given up?

The chairman’s final source of spectrum for hitting the 300 MHz mark rests on
the recommendation of the President’s Council of Advisors on Science and
Technology. The group recommended using database technology similar to what’s
being used with TV white spaces to allow commercial broadband providers to
dynamically share 100 MHz of spectrum now used by military radar systems.

That may or may not wash. House Republicans want to boot the military and sell
off the spectrum. The National Telecommunications and
Information Administration says that will cost taxpayers $18 billion and take
10 years. The military has yet to step in, and when the generals stepped into
the ring with LightSquared, that debate ended then and there.

Still, the good chairman’s forecast of achieving 300 MHz by 2015 appears to be
within reason, especially since it no longer rests on the original criteria in
the National Broadband Plan. But the real issue has less to do with whether the
commission will hit its goal, as it does with the undiscussed matter of what the
commission has done, or not done, to quantifiably demonstrate the need to do
so. The continued blind march toward redistributing spectrum to the highest bidders
so Congress can pretend to pay for something is a finite strategy that impedes
rather than promotes the precious innovation that so many reclamation
proponents invoke. Spectrum redistribution will cost taxpayers uncalculated
billions while providing no incentive whatsoever for device makers to build
better receivers, and for and wireless carriers to develop the more
spectrum-efficient transmission methodologies.